Privacy and Cookies
Rayware Limited and
all members of its group of companies, as defined below, ("We" or
“Us”) are committed to protecting and respecting your privacy. Rayware Limited
includes the brands Kilner, Mason Cash, Viners, Typhoon, Price & Kensington and Ravenhead
This policy sets out
the basis on which any personal data We collect from you, or that you provide
to Us, will be processed by Us. Please read the following carefully to
understand our views and practices regarding your personal data and how We will
treat it. By visiting our site you are accepting and consenting to the
practices described in this policy.
Who We are and how to contact Us
For
the purpose of the UK General Data Protection Regulation (UK GDPR), Data
Protection Act 2018 or successor national implementing laws, regulations and
legislation, as amended or updated from time to time(the
“Legislation”), the data controller is Rayware
Limited of 26-32 Spitfire Road Liverpool L24 9BF. You can
also contact Us by email Us at customerservice@rayware.co.uk
As the Controller of your personal
data We are responsible for deciding what personal
information we gather and how we hold and use it. It also means that we are
legally required to notify you of the information contained within this
Ecommerce Website Privacy Policy.
This policy is
effective from 18th November 2021.
Any changes you make to your communication preferences
will be processed by Us within three working days of
our receipt of your instruction; however, you may still receive non-essential
communications in the intervening time between the submission of your change
and when We process that change.
We are registered as a fee payer with the
Information Commissioner’s Office, with registration number: Z7216458.
For all
data protection queries please contact us at dataprotection@rayware.co.uk
What
We will do with information
We want to be fair and transparent about how
We use any data you provide to Us. We will only collect personal information if
it is relevant to our dealings with you and then only those details that are
necessary. We will only keep personal information for as long as We are either
required to by law or as is relevant for the purpose(s) for which it was
collected. In this Ecommerce Website Privacy Policy:
i)
“you” means
an individual who visits our site or otherwise provides information to Us;
“personal data” or “personal information” means any information relating to an identified or identifiable natural person from which you can be identified directly or indirectly. We process your Personal Data in accordance with the Legislation and guidance issued from the ICO amended from time to time
Lawfulness of our Processing
Under the UK GDPR the lawful bases we rely on
for processing personal information about you,:are:
1) We
have a contractual obligation: We Process personal
information about you in order to fulfil any order you place via our site for
future marketing communications that may not meet the soft-opt in requirements
of the Privacy and Electronic Communication Regulations (‘PECR’);
2) Your
consent: where We have asked for your
consent in the box that pops up when you first visit our site and/or as part of
the ordering process for future marketing communications that may not meet the
soft-opt in requirements of the Privacy and Electronic Communication
Regulations (‘PECR’). You are able to remove your consent at any time by
contacting dataprotection@rayware.co.uk.
Personal Information that We collect
We will collect and
process the following data about you:
·
Information
you give Us. This is information about you that you give
Us by filling in forms on our site (our site) or by corresponding
with Us by phone, e-mail or otherwise. It includes information you provide when
you register to use our site, search for a product, place an order on our site,
sign up to our newsletter, register your Viners guarantee, contact us and when
you report a problem with our site. The information you give Us may include
your name, address, e-mail address and phone number, date of birth, demographic
information such as postcode, preferences and interests and other information
relevant to customer surveys and/or offers. When placing an order, we won't store
payment details but will hold your name, email address, phone number and
product ordered in case we need to refer back to this in the case of faulty
goods or claims.
·
Information
We collect about you. With regard to each of your visits to our
site We will automatically collect the following information:
·
technical information, including the Internet
protocol (IP) address used to connect your computer to the Internet, your login
information, browser type and version, time zone setting, browser plug-in types
and versions, operating system and platform;
·
information about your visit, including the
full Uniform Resource Locators (URL), clickstream to, through and from our site
(including date and time), products you viewed or searched for, page response
times, download errors, length of visits to certain pages, page interaction
information (such as scrolling, clicks, and mouse-overs), methods used to
browse away from the page and any phone number used to call our customer
service number.
·
Information We
receive from other sources. This is information We receive about you if you use any other
websites We operate or other services We provide. In this case We will have informed you when We collected that data if We
intend to share those data internally and combine it with data collected on
this site. We will also have told you for what purpose We
will share and combine your data. We are working closely with third parties to
request product reviews by agreeing to our terms and conditions you confirm that we
can send you product review requests. We also use third parties to enable Live
Chat on the site and to process payments. We will notify you when We receive
information about you from them and the purposes for which We intend to use
that information.
Why do We collect it and how do We use it?
ESSENTIAL
USES: We need the personal information We
collect to send you essential information about your purchases and also to help
Us with the operation of our site. For example:
- to allow you to
register to use our site by sending an email to you to confirm your
details and to enable you to commence using our services and purchase our
products;
- to respond to any
queries you raise with Us and otherwise provide customer support;
- to send you
information relevant to our site, such as informing you about changes to
this Ecommerce Website Privacy Policy or maintenance to our site;
- to send you a password
reset link if you tell Us that you have forgotten your password;
- as
part of our efforts to keep our site safe and secure;
- in case We have any
queries concerning any aspect of your use of our site;
- to ensure that
content from our site is presented in the most effective manner for your device;
- to
allow you to participate in interactive features of our site when you choose to
do so;
- to administer
our site and for internal operations, including troubleshooting, data analysis,
testing and research;
- to
measure or understand the effectiveness of advertising We serve to you and
others;
- to prevent or
investigate prohibited activity; and,
- to enforce the terms and
conditions relating to any sale of goods via our site.
You
have the right to ask Us to restrict processing of your personal data, to
withdraw consent were we are relying on it to process your personal data and a
right to object to our processing of your personal data in this way. If you exercise
either of these rights you may not be able to make full use of our site and/or
We may not be able to provide you with information that you have requested Us
to provide to you.
NON-ESSENTIAL USES: We may also use personal information about you for non-essential uses,
where you have opted in to such use. If
you have opted in, you can choose to opt out at any time by contacting Us as We
set out at the start of this Ecommerce Website Privacy Policy or updating your
preferences in your online account on our site.
For example, We may use personal information to
send you promotional or marketing information about Us, our newsletters (where
you subscribe to receive them) or
anything in which you show an interest.
Reviews - We share your name, email address and the product/service you purchased (as obtained during the order process) with Feefo, who will send you an email on our behalf asking you to complete a review. Our legal basis for doing this is our legitimate interest in asking for feedback to improve our products and services. Please see Feefo’s privacy policy for more information on how Feefo uses the reviews you submit.
Information
We collect that is not personal information
Information that is not personal information
is not protected by data protection law but We may use
such information in the following ways:
·
We may anonymise data about our site users
generally and use it for a range of purposes, including ascertaining the
general location of users. This anonymised
data is incapable of being used to identify anyone personally.
·
We may aggregate user information so that it
is impossible from the aggregated set of data to identify anyone individually,
which is valuable to Us for the purposes of analysing market trends. You
confirm that you consent to Us viewing, monitoring, collecting and recording
information input by you into our site, and to our dealing with it on an
aggregated basis, in a manner that does not identify you or attribute any
particular information to you. You also agree to Us collating, compiling,
reformatting, reproducing, adapting, translating, arranging, publishing,
selling, distributing, dealing with or otherwise commercially exploiting any
part of such information or otherwise making it available to any third party on
such terms as We deem appropriate. Please rest assured that this will not
include personal data.
Who do We give information to?
We will not sell, distribute or lease your
personal information to third parties unless We have
your permission or are required by law to do so. We may pass personal information to people
who process data for Us. We have contracts with these people and We ensure they are contractually bound to do only what We
say they can do with your information. We may pass details about you to our agents
and subcontractors to help Us with any of our uses of your data set out in this
Ecommerce Website Privacy Policy; for example, We may use third parties to
assist Us with providing the administration for running our site, to analyse
data and to provide Us with marketing or customer service assistance.
However, you agree that We have the right to
share your personal information with:
Any member of our
group, which means our subsidiaries, our ultimate
holding company and its subsidiaries, as defined in section 1159 of the UK
Companies Act 2006. We own the following brands; Viners, Kilner, Mason Cash, Typhoon, Price
& Kensington and Ravenhead.·In limited circumstances, where permitted by law, we may
need to share your personal data with:
·
a prospective seller of buyer in the event
that We sell or buy any business or assets;
·
a third party, if Rayware Limited or
substantially all of its assets are acquired by a third party, in which case
personal data held by it about its customers will be one of the transferred assets;
and,
·
crime prevention or
detection agencies and bodies involved in the administration of justice (e.g.
to provide information to the police, Serious Fraud Office, or to courts or
tribunals)
·
If We are under a duty to disclose or share
your personal data in order to comply with any legal obligation, or in order to
enforce or apply our terms
of use and other agreements; or to protect the rights,
property, or safety of Us, our customers or others. This includes exchanging
information with other companies and organisations for the purposes of fraud
protection and credit risk reduction.
We may also disclose your details as
described elsewhere in this Ecommerce Website Privacy Policy but We shall not
otherwise sell or disclose your personal data to third parties without
obtaining your prior consent unless this is necessary for purposes set out
above in this Ecommerce Website Privacy Policy.
As stated above, We
may commercially exploit any anonymised or aggregated information on the basis
that no individuals are identified or identifiable.
Third
party websites
Our site may contain links to other websites of interest.
However, once you have used these links to leave our site, you should note that
We do not have any control over that other website. Therefore, We cannot be responsible for the protection and privacy of
any information which you provide whilst visiting such websites and such websites
are not governed by this Ecommerce Website Privacy Policy. You should exercise caution and look
at the privacy policy applicable to the website in question.
Communication, engagement and
actions taken through external social media platforms on which We may participate on are subject to the terms, conditions
and privacy policies held with each social media platform respectively. We will never ask for personal information
through social media platforms and We encourage users wishing to discuss
sensitive details to contact Us through primary communication channels such as
by telephone or email. Our site may use
social sharing buttons which help share web content directly from web pages to
the social media platform in question. You are advised before using such social
sharing buttons that you do so at your own discretion and note that the social
media platform may track and/or save your request to share a web page through
your social media platform account.
How We store your Personal Data.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. We comply with current best practice guidelines for the retention of your Personal Data. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data We hold and the potential risk of harm from unauthorised use or disclosure of your personal data.
Where We store your Personal Data
We have in place appropriate technical and security measures to prevent unauthorised or unlawful access to or accidental loss of or destruction or damage to your information. We store your personal details on a secure server. We use firewalls on our servers. Where We have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. You are responsible for protecting against unauthorised access to your password and to your computer and you must not share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. We have put in place procedures and technologies to maintain the security of your personal data from the point of collection to the point of destruction. We cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access. We endeavour to mitigate any external risks effecting the security of your personal data through technical and organisational measures.
The data that We collect from you may be transferred to, and stored at, a destination outside the United Kingdom. Where there are adequacy regulations in respect of those countries this means that when We transfer your data they are deemed to provide an adequate level of protection for your personal protection. Where there are no adequacy regulations in respect of a country We will ensure that your Personal Data receives an adequate level of protection to ensure that your personal information is treated by those third parties in a way which is consistent with and which respects UK law on data protection,.
By submitting your Personal Data, you agree to this transfer, storing or Processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Ecommerce Website Privacy Policy and in accordance with the appropriate safeguards as required by relevant data protection law. To obtain further details and a copy of the appropriate safeguards please contact customerservice@rayware.co.uk
To limit the risk of
any personal data being breached, We have put in place
appropriate security measures. This includes limiting access to your personal
data to our employees. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.
All key Rayware Ltd employees
have received data protection training and data protection awareness has been
communicated within the wider team. We take the following steps to
maintain data security:
·
only a few members of staff have access to our website data;
·
passwords are updated regularly;
·
We do not hold passwords for customer accounts;Our
building is secured with key fob access during business hours;
·
visitors are required to sign in and out at reception;
·
the building is secured overnight with only senior members of staff having
access;
·
system updates are installed in a timely fashion after release; and,
·
our web site(s) are hosted by UK Fast who are fully compliant with UK
data protection legislation.
Your
rights
You
have the following rights in respect of your personal information:
i)
Right of access: the right
to request from Us copies of your personal data;
ii)
Right to rectification: the right
to ask Us to rectify personal information you think is
inaccurate. You also have the right to ask us to complete information you think
is incomplete;
iii)
Right to erasure: the
right to request erasure of your personal data in certain circumstances;
iv)
Right to restriction of processing: the
right to ask Us to restrict processing of your personal data and a right to
object to our processing of your personal data (but if you do either of these, it may impact on your use of our site
and/or We may not be able to provide you with information that you have
requested Us to provide to you);
v)
Right to object to processing: the
right to object to the processing of your personal information in certain
circumstances;
vi)
Right to data portability: the
right to ask that We transfer the personal information we have about you to
another organisation, or to you, in certain circumstances.
vii)
Right to lodge a complaint
about how We treat your personal data with the
Information Commissioner’s Office.
You
are not required to pay any charge for exercising your rights. If you make a
request, we have one month to respond to you.
If you wish to discuss or make a request in
respect of any of the above rights, please contact Us at customerservice@rayware.co.uk
How long we keep personal information
If you agree to be added to our mailing list,
We will keep your personal information for that purpose unless and until you
tell Us that you want to unsubscribe or be removed from the list. If you advise that you do not want to be
added to our mailing list or you ask to be removed, We
will delete your Personal Data (aside from keeping a record that you have asked
Us not to send you marketing information).
Other personal information will be stored
only for so long as We continue to need it, which will
vary depending on the nature of the information and the purposes for which We
are Processing it. Any information We
hold will be protected by the terms of this Ecommerce Website Privacy Policy and,
once no longer required and We have no further legitimate reason to retain it,
it will be securely destroyed.
Kilner Retail Privacy Policy
The Kilner Retail Store is part of The Rayware Group and the above conditions are applicable to personal data collected in store.
1. What data we collect about you
When you shop with us in store, we process your payment card information where credit or debit cards are used for payment.
We may also ask if you would like an email receipt. If you consent to this, your email will be stored in our secure till system. We will not use your email address to send marketing information to unless you have provided consent for this to happen.
The information you give us may include your name, email address, phone number, debit or credit card information. Any information you provide to us will only be used for the reason(s) you provided it and will not be stored for longer than the purpose that it was provided for.
As per our Think 25 policy and government guidelines in relation to selling knives, we will challenge anyone who appears under the age of 25 to provide identification such as a driving license or passport, to confirm that they are over 18. We will confirm that you have provided ID via our till system.
2. How we collect Personal Data
We collect personal data from you by the following means:
Information you give us when:
• Entering into transactions
• Filling in forms or providing information in store
• By corresponding with us by phone, email, or in person
• Entering into competitions,
• Taking part in customer surveys.
• Signing up to our mailing lists.
3. How we use your Personal Data
For marketing purposes where you have consented to receive marketing communications.
For processing payments or refunds in store.
To gather feedback on our products and services via a customer survey.
To confirm that you are over 18 when purchasing knives or other bladed items.
To contact competition winners.
4. Sharing of Personal Data
Please see the above section titled ‘Who do We give information to?’
5. Storing your Personal Data
Please see the above section titled ‘Where We store your Personal Data’
6. How long is Personal Data kept for?
Please see the above section titles ‘How long we keep personal information’
Cookies
A cookie is a small
file which asks permission to be placed on your computer’s hard drive. Once you
agree, the file is added and the cookie helps analyse web traffic or lets you
know when you visit a particular website. Cookies allow web applications to respond
to you as an individual. The web application can tailor its operations to your
needs, likes and dislikes by gathering and remembering information about your
preferences.
We use necessary cookies
which make the website useable by enabling basic functions like page navigation
and access to secure areas of the website. The website cannot function properly
without these cookies.
We use traffic log
cookies to identify which pages are being used. This helps Us
analyse data about web page traffic and improve our site in order to tailor it
to customer needs. We only use this information for statistical analysis
purposes and then the data is removed from the system.
Overall, cookies help
Us provide you with a better website, by enabling Us to monitor which pages you
find useful and which you do not. A cookie in no way gives Us access to your
computer or any information about you, other than the data you choose to share
with Us.
You can choose to
accept or decline cookies. Most web browsers automatically accept cookies, but
you can usually modify your browser setting to decline cookies if you prefer.
This may prevent you from taking full advantage of our site. You can find out
how to reject or delete cookies by following the instructions for your browser
set out here
http://www.aboutcookies.org.uk/managing-cookies
Changes
to our Ecommerce Website Privacy Policy
We keep our practices and
policies regarding the collection, processing and security of personal data
under continual review and may update them from time to time. We therefore
reserve the right to change this Ecommerce Website Policy at
any time. Any changes We make to our Ecommerce Website Privacy Policy in the
future will be posted on this page and, where appropriate, notified to you by
e-mail. Please check back frequently to see any updates or changes to our Ecommerce
Website Privacy Policy. Each time you
enter or use our site, you agree that the Ecommerce Website Privacy Policy current
at that time shall apply to all information which We hold about you.
Consent
Where you have given Us consent to use your
personal information in any way, you have a right to withdraw that consent at
any time.
By visiting our site and/or submitting data
to Us, and having ticked the opt-in boxes in the pop-up cookies and privacy
notice asking for consent, you consent to our use of your data in the manner
described in that privacy notice (as explained further in this Ecommerce Website
Privacy Policy, as amended from time to time). You also consent to the
placement by Us of cookies on your access device, the cookies being used for
the purposes set out in this Ecommerce Website Privacy Policy and which may
contain personal information about you.
If
you have any concerns about the use of your personal information, you can make
a complaint to us at dataprotection@rayware.co.uk.
You
can also complain to the ICO if you are unhappy with how we have used your
data.
Information Commissioner’s Office
Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk
The ICO’s address:
Wycliffe
Water
Lane
Wilmslow
Cheshire
SK9
5AF
